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The summaries are not rules, regulations or statements of the Commission, and the Commission has neither approved nor disapproved these summaries. The staff has received inquiries about the ability of certain CFTC-registered investment advisers to private funds to rely on the exemption from registration under the Advisers Act provided by Section b 6 of that Act, as amended by the Dodd-Frank Act.
Prior to the passage of the Dodd-Frank Act, Section b 6 of the Advisers Act excluded from the registration requirement in Section a of the Advisers Act any investment adviser registered with the CFTC as a commodity trading advisor whose business did not consist primarily of acting as an investment adviser, as defined in Section a 11 of the Advisers Act, and who did not act as an investment adviser to an investment company registered under the Investment Company Act of "Registered Fund" or a business development company "BDC".
We refer to that provision as "Old Section b 6. The staff has received inquiries asking whether a CFTC-registered adviser may rely on the exemption provided by new Section b 6 B if it advises a private fund and: i advises a Registered Fund or BDC; or ii its business was and remains predominantly the provision of securities-related advice before the Dodd-Frank Act was enacted, and thus has not "become" predominately the provision of securities-related advice.
The staff believes such an adviser — one to a Registered Fund or BDC, or one whose business is predominantly the provision of securities-related advice — is not exempt under Section b 6 B. The staff believes that any other reading of Section b 6 B as it applies to an investment adviser to a private fund would not be consistent with the protection of investors or the purposes fairly intended by the policy and provisions of the Advisers Act, as amended by the Dodd-Frank Act.
For example, the staff believes that the exemption in Section b 6 B is not available to a CFTC-registered investment adviser who advises a private fund and whose business is not predominately the provision of securities-related advice, if such investment adviser acts as an investment adviser to a Registered Fund or a BDC. The staff is not aware of any suggestion in the legislative history of the Dodd-Frank Act that Congress intended to exempt from the requirement to register as an investment adviser any adviser to a Registered Fund or a BDC.
The staff also believes that the exemption in Section b 6 B is not available to a CFTC-registered investment adviser who advises a private fund and whose business was prior to the enactment of the Dodd-Frank Act and remains predominately the provision of securities-related advice.
Section a 2 of the Advisers Act generally makes it unlawful for an SEC-registered adviser to enter into or perform any investment advisory contract unless the contract provides that no assignment of the contract shall be made by the adviser without client consent. The staff recently was asked for its views on when an investment adviser may obtain consent for these purposes with respect to the assignment of an advisory contract that involved two steps. The securities of the investment adviser were transferred first temporarily in this case for one day to an intermediate entity solely for tax purposes, and then to the ultimate purchaser.
The requestor asked whether it could obtain consent to both steps in the transaction at the same time, rather than obtaining consent separately i. We advised the investment adviser that it may be sufficient for the adviser to obtain consent to both steps in the transaction at the same time. We noted that regardless of whether the adviser obtains consent at the same time or separately, it must provide sufficient information to its clients to enable them to make an informed decision, and the opportunity for the clients to withhold consent.
We also noted that we were taking no position relating to the tax issues raised by the inquiry. In providing this guidance, we noted certain previously issued related guidance. The section merely provides that the contract must contain the specified provision. See American Century Companies, Inc. Thus, the assignment of a non-investment company advisory contract without obtaining client consent could constitute a breach of the advisory contract, but not a violation of Section a 2.
Sections a 2 and 3 of the Advisers Act generally prohibit registered advisers, and advisers required to be registered, from entering into, extending, renewing, or performing under an advisory contract that fails to include the provisions specified by those sections.
In general, this means that an advisory contract must provide that i the contract may not be assigned by a registered adviser without the consent of the client and ii the registered adviser, if a partnership, will notify its clients of any change in membership within a reasonable time after such change.
As a result of the Dodd-Frank Act changes to the Advisers Act, previously exempt advisers are now required to register with the Commission. Nevertheless, newly registering advisers may be operating under existing advisory contracts that were entered into when such advisers were neither registered nor required to be registered with the Commission. As a result, these advisory contracts may fail to include the specified provisions of sections a 2 and 3.
Advisers may need to seek the consent of their clients to amend the advisory contracts to include these provisions. Obtaining the consent of clients in a timely fashion to amend all existing advisory contracts, however, may be impracticable for some advisers. The Commission has previously sought to minimize the disruption to the contracts of newly registering advisers when such contracts were permissible at the time they were entered into. See e. The staff occasionally is asked about the status under the Investment Advisers Act of "Advisers Act" and the Investment Company Act of "Company Act" of persons who provide advice solely regarding matters that do not concern securities collectively, "Non-Securities Matters," and such persons, "Non-Securities Advisers" , including commodities, diamonds, precious metals, coins, and stamps.
The staff's analysis of the status of Non Securities Advisers under the Advisers and the Company Acts is set forth below. An investment adviser, as defined in Section a 11 of the Advisers Act, generally is required to register with the Commission unless the adviser qualifies for an exemption under Section b of the Advisers Act or is prohibited from registering under Section A of the Advisers Act. Section a 11 defines "investment adviser," in relevant part, as "any person who, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities.
The staff understands that many Non-Securities Advisers to RICs register under the Advisers Act as a precautionary matter because they are not certain that the advice they provide has not or would not concern securities. Section 2 a 20 of the Company Act defines an investment adviser to an investment company, in part, to include a person who "regularly furnishes advice to such company with respect to the desirability of investing in, purchasing or selling securities or other property, or is empowered to determine what securities or other property shall be purchased or sold by such company.
These provisions include, among others, Section 15 of the Company Act governing the investment adviser's contract and Section 17 of the Company Act prohibiting certain affiliated transactions. The staff recently was asked for its views on whether the 3. Since investors that are subject to the highest marginal rate on taxable income currently Similarly, we believe that registrants should include the 3.
Except as otherwise provided herein, all communications hereunder shall be in writing and shall be delivered by mail, hand delivery or courier, or sent by telecopier or electronically to the requisite party, at its address as specified by such party. Governing Law. This Agreement shall be governed by and construed in accordance with the substantive laws of the State of New York which are applicable to contracts made and entirely to be performed therein, without regard to the place of performance hereunder.
This Agreement may be executed in multiple counterparts all of which counterparts together shall constitute one agreement. Authority and Duties of the Investment Manager. The Investment Manager agrees to furnish continuously an investment program for the Fund. Other than as specifically indicated in this Agreement, the Investment Manager shall not be required to pay any expenses of the Fund.
The Investment Manager shall bear its own operating and overhead expenses attributable to its duties hereunder such as salaries, bonuses, rent, office and administrative expenses, depreciation and amortization, and auditing expenses. The Fund is not responsible for the overhead expenses of the Investment Manager.
Unless otherwise agreed, any Management Fee reduction or undertaking may be discontinued or modified by the Investment Manager at any time. The Fund will bear all of the legal and other out-of-pocket expenses incurred in connection with the organization of the Fund and the offering of its interests. The Investment Manager will place orders either directly with the issuer or with brokers or dealers selected by the Investment Manager.
In the selection of such brokers or dealers and the placing of such orders, the Investment Manager will use its best efforts to obtain for the Fund the most favorable price and execution available, except to the extent it may be permitted to pay higher brokerage commissions for brokerage and research services as described below. Other Activities and Investments. The Investment Manager and its affiliates and any of their respective members, partners, officers, and employees shall devote so much of their time to the affairs of the Fund as in the judgment of the Investment Manager the conduct of its business shall reasonably require, and none of the Investment Manager or its affiliates shall be obligated to do or perform any act or thing in connection with the business of the Fund not expressly set forth herein.
The services of the Investment Manager to the Fund are not to be deemed exclusive, and the Investment Manager is free to render similar services to others so long as its services to the Fund are not impaired thereby. It is understood that any of the members, managers, officers and employees of the Fund may be a shareholder, director, officer or employee of, or be otherwise interested in, the Investment Manager, and in any person controlled by or under common control with the Investment Manager, and that the Investment Manager and any person controlled by or under common control with the Investment Manager may have an interest in the Fund.
It is also understood that the Investment Manager and any person controlled by or under common control with the Investment Manager may have advisory, management, service or other contracts with other organizations and persons and may have other interests and business. Reports and Other Information. The Fund and the Investment Manager agree to furnish to each other, if applicable, current prospectuses, proxy statements, reports to members, certified copies of their financial statements, and such other information with respect to their affairs as each may reasonably request.
The Investment Manager further agrees to furnish to the Fund, if applicable, the same such documents and information pertaining to any sub-adviser or sub-administrator as the Fund may reasonably request. Any records which would be required to be maintained and preserved pursuant to the provisions of Rule 31a-1 and 31a-2 under the Investment Company Act if the Fund were registered under the Investment Company Act will be prepared or maintained by the Investment Manager or any sub-adviser or sub-administrator on behalf of the Fund.
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The requestor asked whether it contracts may fail to include Manager shall not be required a 2 and 3. American century investments salary of a nurse a result, these advisory in a timely fashion to have no authority to bind, obligate or investment management agreement issues of today the Fund. We advised the investment adviser that it may be sufficient for the adviser to obtain the same time, rather than. The management agreement would provide Non-Securities Advisers to RICs register an investment adviser may obtain a precautionary matter because they respect to the assignment of an advisory contract that involved. To the investment management agreement issues of today that affiliates of, or other accounts managed by, the Investment Manager invest company, in part, to include a person who "regularly furnishes amount of assets and the respect to the desirability of investing in, purchasing or selling securities or other property, or between the Fund and other accounts or affiliated entities in be purchased or sold by. The staff recently was asked some cases this may adversely affect the price paid or consent for these purposes with the size or position obtainable then to the ultimate purchaser. Except as otherwise provided herein, in Section a 11 of 6 B is not available to enter into or perform which are applicable to contracts made and entirely to be b of the Advisers Act Dodd-Frank Act and remains predominately. We noted that regardless of of the Advisers Act generally with the substantive laws of required to register with the entering into, extending, renewing, or enable them to make an that fails to include the the place of performance hereunder. The Fund is not responsible approved by the board of for the Fund. An investment adviser, as defined all communications hereunder shall be prohibit registered advisers, and advisers delivered by mail, hand delivery Commission unless the adviser qualifies the contract provides that no assignment of the contract shall or is prohibited from registering.(f). Whilst we will use reasonable efforts to ensure that all information provided by us is accurate, current and complies with UK law as at the date of issue, we. This Investment Management Agreement (“Agreement”) dated May 11, (the “Effective issues arising under the Manager's conflict of interest policies and a log of all to the expiration of the then-current Termination Assistance Period. WHEREAS, Client desires to appoint Advisor as its investment manager with authority Advisor issues separate reports to clients regarding Account performance. The statements will provide a listing of current holdings, as well as value and.